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Ethics and Compliance

Conflict Minerals – Special Disclosure Report

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In August 2012, the U.S. Securities and Exchange Commission (SEC) adopted Rule 13p-1 to implement reporting and disclosure requirements related to conflict minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank Act). The Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain so called conflict minerals that are necessary to the functionality or production of their products. “Conflict minerals” are defined as cassiterite, columbite-tantalite, gold, wolframite and their derivatives, which are limited to tin, tantalum, tungsten and gold (3TG).

The Rule is intended to address concerns that conflict minerals originating from the Democratic Republic of the Congo or an adjoining country (the Covered Countries) may help finance armed groups that are responsible for violence and human rights violations in the region. The disclosures are intended to increase transparency in the supply chain and strengthen custody controls surrounding conflict minerals, thereby reducing funding for the armed groups. The disclosure requirements apply to registrants whatever the geographic origin of the conflict minerals and whether or not the conflict minerals fund armed conflict in the Covered Countries.

Cummins developed a cross-functional team with representatives from Purchasing, Quality, Legal and Ethics and Compliance to develop and implement a conflict minerals program. We implemented a conflict minerals policy and related procedures and processes to evaluate the use and source of 3TG minerals in our products. Our policy is to eliminate procurement, as soon as commercially practicable, of products containing conflict minerals obtained from sources that fund or support inhumane treatment in the Covered Countries.

A copy of our conflict minerals disclosure and any related exhibits is available by clicking on the link below.